Allergen Management in Ireland and the UK: The 14, PPDS and Cross Contact

Allergens are the leading cause of food recalls in the UK and Ireland, and it is not close. In the first quarter of 2026, undeclared allergens accounted for 57% of everything pulled from UK shelves.

Almost none of it was a hygiene failure. It was labels that did not match what was in the pack, and that is a records problem.

The 14 you have to declare

Regulation (EU) 1169/2011 applies in Ireland and is retained in UK law. It names fourteen allergens that must be declared:

Milk is the most frequently undeclared allergen in UK recalls, with gluten and wheat second. Both usually arrive through shared production lines rather than through the recipe.

Prepacked for direct sale, and Natasha’s Law

This is the change that caught out most small food businesses, and it still catches people.

Prepacked for direct sale, or PPDS, means food packed on the same premises from which it is sold, before the customer orders it. A sandwich made in the morning and put in a chiller is PPDS. A sandwich made to order is not.

In 2016 Natasha Ednan Laperouse, aged fifteen, died after eating a baguette containing sesame that was not declared on the label. The product was PPDS, a category that at the time did not require a full ingredient list.

The Food Information (Amendment) Regulations, known as Natasha’s Law, came into force in the UK in October 2021 and require PPDS foods to carry the name of the food and a full ingredient list, with the fourteen allergens emphasised within it. Ireland has equivalent requirements for PPDS foods, and you should confirm your own position with the FSAI.

Loose and non prepacked food

Allergen information must still be provided for food sold loose, such as at a deli counter or in a restaurant. It can be given verbally, provided there is clear signposting telling customers to ask and the information given is accurate and consistent.

Verbal does not mean informal. The answer has to come from your ingredient records rather than from whoever happens to be on the counter, and it needs to be the same answer every time.

Precautionary labelling, and its limits

Statements such as "may contain nuts" are voluntary and not legally defined. There is no threshold behind them, no standard wording, and no requirement to use them.

Two things follow:

• They are not a substitute for control. Applying "may contain" to everything because cross contact is possible somewhere is not risk management, and consumers with allergies have learned to distrust blanket warnings.
• They must be based on an actual risk assessment. If you use precautionary labelling, be able to show why: the shared line, the cleaning validation, the reason the risk cannot be designed out.

Cross contact control

Where the work actually is. Four controls, and each one has to be evidenced rather than described.

Production sequencing

Run allergen free product first, then work up through allergen containing runs, with a full clean down before returning to the start. Record the sequence, not just the policy. This is the primary control in a bakery, where airborne flour and shared mixers make physical separation impractical.

Dedicated equipment

Separate utensils, boards, containers and where possible separate lines. Colour coding works if it is used consistently rather than decoratively, and it needs to survive a busy service and a new starter.

Cleaning validated for allergens

Visually clean is not allergen clean. Protein residue can remain on a surface that looks spotless, which is why allergen clean downs need a defined method and, in higher risk operations, verification by swabbing rather than by eye.

Decanting and storage

When product leaves its original packaging, the allergen information leaves with it unless somebody carries it across. That transfer is a task with a record, particularly in a deli where decanting happens all day.

Supplier specification changes, the failure nobody sees

The most common route to an allergen recall is not carelessness on your floor. It is a supplier reformulating an ingredient and the change reaching your label late, or not at all.

The 2024 mustard powder contamination is the clearest recent example. Peanut contamination in a single ingredient travelled through the supply chain to 59 brands and 307 products, and related recalls were still appearing in 2026.

What protects you is boring and specific:

1. Hold allergen information against every ingredient, not against the finished product
2. Require suppliers to notify specification changes, in writing, as a condition of approval
3. Flag any change for label review with a named owner and a closing date
4. Keep batch level traceability so you can identify which runs used which lot
5. Re review specifications on a schedule rather than waiting to be told

What about certification?

There is no allergen certification that Irish or UK retailers routinely ask for. What they ask for is BRCGS or a comparable scheme, and allergen management sits inside it as a graded requirement covering specifications, product authenticity, labelling and cross contact control.

Schemes you may see referenced, such as VITAL from the Allergen Bureau in Australia or the US gluten free certification programmes, are real but are driven by specific export markets or product claims rather than by the UK and Irish multiples. Ask your customer what they need before certifying against anything.

Frequently asked questions